When planning work safety observation programs, observers should be trained to recognize and report hazards (unsafe conditions) and management system deficiencies in addition to unsafe acts.

Part 2 of this article offers recommendations for securing management commitment to comprehensive safety and warns against instilling a blame culture.

Part 1 of this article (PS, January 2017, pp. 36-45) discussed the three key elements of a modern occupational safety program: engineering and technical standards and controls, management and operation systems, and human factors. Each element plays an important role, yet many organizations continue to stress one at the expense of the others, which creates an unbalanced and ineffective OSH program. The human factor is present in most every incident, yet often the focus is too narrowly trained on blaming at-risk behaviors or unsafe acts rather than on identifying and addressing the conditions, systems and norms that enable or cause those errors.

Part 2 of this article examines how employers can better incorporate engineering and system elements into worker-oriented initiatives to create a more comprehensive approach to OSH and thereby better understand incident causes, reduce incident rates, confirm regulatory compliance, and prevent serious injuries and fatalities.

Proving Due Diligence

While some allege that companies may use behavior-based safety (BBS) as due-diligence or reasonable-care proof in potential litigation (United Steelworkers Local 343, 2000), in the author’s opinion, BBS observation documentation does not appear to be strong in that regard, as it is typically based on basic observations of workers’ behaviors by nonprofessionals, and often has nothing to do with recognizing and controlling occupational hazards. Traditional regulatory compliance-based safety systems should be expected to provide due diligence.

Only Applicable to “Best in Class”?

BBS programs are often recommended for best-in-class companies that already have engineering controls and systems in place and an excellent safety culture. Implementation in less-advanced safety systems may be less ideal.

For example, “Practical Guide for Behavioral Change in the Oil and Gas Industry,” states:

During the past 10 years, large improvements in safety have been achieved through improved hardware and design, and through improved safety management systems and procedures. However, the industry’s safety performance has leveled out with little significant change being achieved during the past few years. A different approach is required to encourage further improvement. This next step involves taking action to ensure that the behaviors of people at all levels within the organization are consistent with an improving safety culture. (Step Change in Safety, 2001)

The potential effect of behavior modifications on safety performance (incident rates) is illustrated in Figure 1 (p. 48). The conclusion suggested by Figure 1 is that significant incident reduction can be achieved through engineering and systems controls. When those two are addressed, an organization can then work on behavioral modifications for further improvements. At that advanced stage, the unsafe behavior component may become a significant source of injuries; engineering and systems components are “completely” corrected, and any further improvement is impossible. It appears, however, that neither of these stages likely exists in a pure form, and engineering and systems controls must be continuously maintained and improved.